Alternative Tax Regimes
Thinking of moving your tax residence to Greece?
Law 5313/2026: what has changed for HNWIs, pensioners, and fund managers
Greece offers attractive alternative tax regimes for individuals who move their tax residence to the country. Law 5313/2026, together with the decisions issued by the Independent Authority for Public Revenue (AADE) in July and September 2026, has made these regimes easier to access and has given fund managers clear rules for operating from Athens.
The choice you make can shape your tax position for up to 15 years. At Crowe Greece, our Tax Advisory team helps high-net-worth individuals with their families, foreign pensioners, investment professionals, and family offices choose the right regime, apply correctly and on time, and stay compliant year after year.
As part of Crowe Global, with member firms in more than 150 countries, we work alongside your advisers at home, so that your move is planned on both sides before you arrive.
Non-Dom Regime (Article 5A GITC)
Individuals who move their tax residence to Greece can pay a flat annual tax of €100,000 on all their foreign-source income, whatever the amount, for up to 15 years. Family members can be included for an additional €20,000 each per year, and assets held abroad are exempt from Greek inheritance and gift tax. Income from Greek sources is taxed under the general rules. Taxpayers under the regime receive a Greek tax residence certificate and can benefit fully from Greece’s double tax conventions.
Key requirements
✓ No Greek tax residence in 7 of the 8 years before the move
✓ An investment of at least €500,000 in Greece, for example in real estate, Greek companies, or securities, completed within three years of the application
✓ Application by 30 September of the year of arrival, or of the following year (AADE Decision A.1147/2026)
✓ Annual tax payable by the last working day of December
| What changed in 2026: the fixed 31 March application deadline has been abolished, the annual tax is now due in December instead of July, and the obligation to pay the first year’s tax within 30 days of approval no longer applies. |
Our services include:
✓ Eligibility review and comparison with the 5B and 5C regimes
✓ Tax planning before the move, coordinated with your advisers abroad
✓ Preparation and submission of the application to AADE
✓ Tax structuring of the €500,000 investment
✓ Reports by certified auditors confirming that the €500,000 investment has been made and is maintained, as required by law.
✓ Tax compliance for Greek-source income and annual tax returns
Foreign Pensioners (Article 5B GITC)
Pensioners who move their tax residence to Greece can pay a flat 7% tax on all their foreign-source income for up to 15 years. Taxpayers under the regime receive a Greek tax residence certificate and can benefit fully from Greece’s double tax conventions.
Key requirements
✓ No Greek tax residence in 5 of the 6 years before the move
✓ Moving from a country that has an administrative cooperation agreement with Greece on tax matters
✓ Application by 31 October of the year of arrival, or of the following year (AADE Decision A.1192/2026)
✓ Annual tax payable by the last working day of December
| If you moved to Greece by 2 July 2026, you can still apply for tax year 2026 until 31 October 2026. |
Our services include:
✓ Eligibility review
✓ Application to AADE and transfer of tax residence
✓ Annual tax returns and payment calculations
✓ Advice on Greek-source income and assets held in Greece
Brain Re-gain Regime & Carried Interest (Article 5C GITC)
Professionals who move to Greece to take up employment or start a business can be exempt from tax on 50% of that income for seven years. Since 1 January 2026, the regime also opens the way to a reduced tax rate on carried interest for investment professionals.
Key points
✓ Brain re-gain regime: no Greek tax residence in 5 of the 6 years before the move, relocation from an EU or EEA country or a country with an administrative cooperation agreement with Greece, and a commitment to stay in Greece for at least two years
✓ Carried interest paid to employees of Greek entities that provide services to EU alternative investment fund managers (AIFMs), or to equivalent non-EU managers, is taxed as a capital gain at a flat 15%
✓ The rate falls to 5% for up to seven years where the individual moves to Greece under the brain re-gain regime and the Greek entity spends at least €3 million a year in Greece
✓ Carried interest relating to the period before the move and before the Greek employment began is not taxed in Greece
✓ Qualifying managers must not be established in a non-cooperative jurisdiction and must be supervised by an authority accredited by IOSCO
Our services include:
✓ Eligibility review for relocating professionals and their employers
✓ Carried interest and performance fee planning
✓ Payroll and employment tax set-up
✓ Review of the €3 million annual expenditure condition
✓ Ongoing tax compliance
Funds & Fund Managers
Law 5313/2026 gives alternative investment funds (AIFs) and their managers clear rules for operating from Greece, so that an Athens presence does not, by itself, shift the funds’ tax position.
Key points
✓ Managing qualifying AIFs from Greece, including under delegation, does not create a place of effective management in Greece. The same applies to asset-holding or investment entities in which the funds hold at least 95%
✓ Services provided by Greek entities do not, by themselves, create a permanent establishment for the funds, their managers, or affiliated entities
✓ Facilities used solely for regulatory compliance and supervision do not constitute a permanent establishment
✓ Qualifying funds are EU AIFs and equivalent non-EU funds that are not established in a non-cooperative jurisdiction and are supervised by an authority accredited by IOSCO
✓ The funds remain taxable where they are established, while the Greek service entities are fully taxable in Greece
| Effective dates: the permanent establishment and effective management rules apply to tax years beginning on or after 1 January 2026. Certain provisions for third-country AIFs apply from 1 January 2025. |
Our services include:
✓ Set-up of the Greek service entity
✓ Permanent establishment and effective management review
✓ Transfer pricing for intra-group service fees
✓ Accounting, payroll, and tax compliance
✓ Coordination with the fund’s advisers abroad, through a single point of contact
WHO WE ADVISE
Advising individuals and businesses at every stage
We advise individuals and businesses at every stage of a move to Greece, and the advisers who act for them abroad.
✓ High-net-worth individuals relocating to Greece, on their own or with their families
✓ Executives, entrepreneurs, and investment professionals taking up work in Greece
✓ Fund managers and the Greek entities that serve them
✓ Private banks, family offices, lawyers, and Crowe member firms acting for clients abroad
✓ Foreign pensioners making Greece their home
How We Support You
Before the move
We review your eligibility, compare the available regimes, and plan the move with your advisers abroad.
When you apply
We prepare your application to AADE and the transfer of your tax residence, so that every deadline is met.
Year after year
We prepare your annual tax returns and payments and keep you informed of any change in the rules.
We review your eligibility, compare the available regimes, and plan the move with your advisers abroad.
We prepare your application to AADE and the transfer of your tax residence, so that every deadline is met.
We prepare your annual tax returns and payments and keep you informed of any change in the rules.
Key Dates at a Glance
✓ 30 September: application deadline for the non-dom regime, in the year of arrival or the following year
✓ 31 October: application deadline for the foreign pensioners’ regime, in the year of arrival or the following year
✓ Last working day of December: annual payment of the €100,000 flat tax or the 7% tax
✓ 1 January 2026: start of the new carried interest, permanent establishment, and effective management rules
Working with the Crowe Network
Many of our clients are introduced by Crowe member firms around the world. If you are a Crowe colleague advising a client who is considering Greece, bring us in early. We offer:
✓ An introductory call with you and your client to scope eligibility and timing
✓ One coordinated plan across both jurisdictions
✓ Regular updates in English throughout the process
Contact us
This page provides general information and does not constitute tax advice. Please contact us for advice on your specific circumstances.
Ioannis Giannopoulos
General Manager & Director, Tax Advisory ServicesCrowe Greece Advisory
Aspasia Maliagka
Senior Manager, Tax Advisory ServicesCrowe Greece Advisory